Privacy Policy

SMARTe Privacy Policy

23rd August, 2018

SMARTe Inc. (“collectively known as SMARTe) is the world’s Data-As-A-Service platform for sales and marketing. We understand that you care about how information about you is used. This privacy policy describes how SMARTe manages personal information collected, received, or maintained. We collect information pertaining to businesses and business people ("Business Information") and all other types of information through our website and other online services (the "Site").

At SMARTe Inc., we take utmost care to protect your privacy. This privacy policy pertains to the different means of how we collect your information and describes how your personal information is stored and treated.

SMARTe’s Website:

You may access and browse this website without revealing any of your personal information. However, while downloading any of our material which have been developed by our internal Subject Matter Experts OR while subscribing to our blogs/newsletters OR while filling in a demo request form, we may collect your personal information such as your name, phone number or e-mail id that may be necessary to help us provide better customer service and we maintain the highest levels of confidentiality pertaining to your information.

This portion of the policy applies to the Website. It does not apply to any website of any third party, even if the third-party website links to (or is linked from) the website. By accessing, using, and/or submitting information through the Website, you consent to the practices described in this policy with regard to the information collected thereby as described herein. If you do not agree with this policy, you must delete all cookies from your browser cache after visiting the website and refrain from visiting or using the website.

How does SMARTe collect Website Visitor Information?

To browse the Website only, you are not required to provide any personal information. However, we may gather non-personally-identifiable information. Similar to many commercial websites, we utilize “cookies” and other technologies to collect non-personally-identifiable information on visitors to the Website. Cookies allow web servers to recognize the computer used to access a website. Cookies store information accessed through your browser to streamline activities on related web sites, and make the online experience easier and more personalized. Information gathered through cookies and web-server log files may include information such as the date and time of visits, the pages viewed, IP addresses, links to/from any page, and time spent at a site.

Information collected from Website submissions will be used for SMARTe’s internal business purposes, including its investigations, sales, and marketing. We may use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

The website may include options for visitors to submit information to SMARTe, for example, to request a product demonstration, download an article, etc. Such forms may provide the option of submitting personal information, such as your name, job title, company, email address, or phone number. In addition, when submitting information on a Website, your submission will be associated with the IP address you are then using, which is automatically assigned to your computer by your Internet Service Provider.

If you have visited any of the Website and would like to know what information, if any, SMARTe has about you and would like to correct such information or have it deleted, you may contact us at privacy@smarteinc.com. If you do not want us to contact you via phone, you can email us at donotcall@smarteinc.com and we will opt you out.

How does SMARTe use Website Visitor Information?

We use cookie data to measure site traffic and usage activity for purposes of improving and enhancing the functionality of the Website, to look for possible fraudulent activity, to better understand the sources of traffic and transactions on the Website, and/or to serve targeted advertisements. Cookies also allow our servers to remember your account information for future visits and to provide personalized and streamlined information across related pages on the Website. You can choose to disable cookies for the Website but this may substantially limit your ability to use our Website. The use of cookies by our partners, affiliates, tracking utility company, or service providers is not covered by this Policy. We do not have access or control over these cookies.

SMARTe takes measures to maintain the security of its website visitor information, does not license or sell such information to anyone, and will only share such information with a third party who has agreed to keep such information confidential and maintain the security thereof, and only for the purposes of facilitating one of the uses described herein on behalf of SMARTe.

How does SMARTe collect Customer Information?

Visitors to our Site may choose to submit their name, email address and/or other information so that they can learn more about our services, register to take part in a SMARTe-sponsored event, or participate in a survey, contest or sweepstakes, among other things.

In order to use SMARTe products and services, you may be required to register as a user. From time to time, we may use your email address to send you information and keep you informed of products and services in which you might be interested. You will always be provided with an opportunity to opt out of receiving such emails. Your contact information may also be used to reach you regarding issues concerning your use of our Site, including changes to this privacy policy.

You may be a user that has been provided access to the SMARTe’s – Bespoke Contacts and Relevant Contacts solutions through your company license agreement. Your employer may require that one or more users have global rights to access any and all information of every user that has access through the company. If you have questions or concerns regarding the rights of other individuals in your company to access your User Information, Uploaded Information, or Usage Logs, you should raise those concerns with the appropriate person at your company.

SMARTe gives you an option of buying subscription to SMARTe’s solutions via your Credit Card. We will use that information solely for the purpose of fulfilling your purchase request. We will store credit card information in an encrypted form and will not sell, share or use it again without your prior consent. (The only exceptions are described in the sections below on "Disclosures to Service Providers," "Disclosures for Legal Reasons," and "Disclosures to a Buyer of the Company").

How does SMARTe use Customer Information?

Customer Information may be used for SMARTe’s legitimate business interests in connection with your use of the Services, including to respond to user inquiries and fulfill user requests, complete transactions, provide customer service, send administrative information, and to personalize user experience with the Services. We may use Customer Information to better understand our users in general and to improve the content and functionality of the Services. We may use Customer Information to contact you in the future to tell you about services, promotions, opportunities, and other general information about SMARTe we believe will be of interest to you. We may use Customer Information to investigate and prosecute potential breaches of SMARTe security or license agreements.

SMARTe will not disclose Customer Information to any third party except in connection with a legitimate use as set forth herein, in connection with a bona fide legal dispute to which such information is relevant, in response to valid, compulsory legal process, or as otherwise required by law. SMARTe will, whenever possible, obtain confidentiality agreements from any person or entity to whom Customer Information is disclosed and ensure any recipients are committed to employing appropriate technological security measures.

SMARTe employs reasonable security and back-up procedures to protect Customer Information. However, in the unlikely event there is a loss or corruption of Customer Information, SMARTe is not responsible or liable for such loss or corruption. We encourage our users to retain copies of all Uploaded Information on their own system.

SMARTe will use Payment Information solely for the purpose of fulfilling purchase requests. We will store Payment Information in an encrypted form and will not sell, share, or use it again without prior consent.

How does SMARTe get the Business information for its Products?

“Business Contact Information” means any of the following information as used in connection with an individual’s business or profession: Name, Title, Company Name, Business Email Address, Business phone number, Work address, Public professional profile address, and/or supplementary information such as business role and responsibility designations.

Once we have collected business Information about a person or company, we combine multiple mentions of the same person or company into a CONTACTS. The resulting master of Contacts (the "MASTER") is then made available to the users of the Site and our customers and strategic partners.

SMARTe Products and Services

SMARTe collects information regarding companies and their employees, including Business Contact Information on company executives, decision makers, and other employees. The information collected is like that which is typically included on online professional profile, a business card, or business email signature etc. including: name, company name, job title, business email address, business phone number, business address, and corporate website URL. SMARTe gathers, verifies, and organizes this data for purposes of licensing such information to SMARTe clients and strategic partners for sales and marketing purposes.

SMARTe obtains data for its database from web crawling, first-hand research, including telephone interviews and publicly available resources, third-party licensors, and crowd-sourcing etc.; All the business contact information that SMARTe obtains through any of the foregoing means is verified by SMARTe’s technologies and in-house research team, and information that is found to be inaccurate or irrelevant to the purposes of the Services is removed and deleted. SMARTe endeavors to publish highly accurate business contact information on influencers and decision makers and other agents and employees of the companies it profiles.

The General Data Protection Regulation GDPR For EU Residents

SMARTe complies with the recent GDPR regulation by processing data along the GDPR norms. Under GDPR there are six grounds to process personal data, these are equally valid. There are two of these which are relevant to our business (direct B2B marketing) they are: consent or legitimate interest. As Recital 47 of the GDPR states that “The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest.” Using legitimate interest as the basis for B2B marketing involves ensuring key conditions are met:

“The processing must relate to the legitimate interests of your business or a specified third party, providing that the interests or fundamental rights of the data subject do not override the business’ legitimate interest."

"The processing must be necessary to achieve the legitimate interests of the organization.”

Along with the above compliance, SMARTe DOES NOT share personal data with customers / partners, RECORDS all data processing activities, DON’T SOURCE any sensitive information such as religion, political inclinations, gender, age etc., has an EXPLICIT OPT-IN, OPT-OUT process and is proud to be operating for over 15 years without any data breach

As a ‘data processor’, SMARTe Inc. follows the following data privacy requirements honoring the GDPR law (Article 13 and 14). SMARTe provides notice to all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the rights of data subjects provided in Articles 12-23, including the right to be forgotten.

SMARTe informs individuals about the collection and use of their personal data, retention periods for the data, and who it will be shared with. This is a key transparency requirement under the GDPR, provides privacy information to individuals at the time of collecting their personal data. When SMARTe obtains personal data from other sources, we provide individuals with privacy information within a reasonable period of obtaining the data and no later than a month. If any EU resident information is sourced in SMARTe database then SMARTe will provide such individual with a notice detailing the information SMARTe has on such person, the purpose for which it will be used, and informing such person of their rights with respect to such information, including the right to know what information SMARTe possesses on them, to correct such information, or to opt out of data collection entirely. Such persons may opt out of the SMARTe database by emailing privacy@smarteinc.com.

Information we provide to people is concise, transparent, intelligible, easily accessible, and in clear and plain language. We conduct regular review, and where necessary, update our privacy information. If there are any new uses of an individual’s personal data, we make sure to bring it to their attention before we start processing.

Privacy Shield

SMARTe complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. SMARTe has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program (including the Privacy Shield Principles), any rights you may have to binding arbitration before a Privacy Shield Panel, and to view our certification page, please visit https://www.privacyshield.gov.

For information received under the Privacy Shield, SMARTe will require third parties to whom SMARTe discloses personal information to safeguard that personal information consistent with this Policy by contract, obligating those third parties to provide at least the same level of protection as is required by the Privacy Shield Principles. EU and Swiss individuals may choose to opt-out of such disclosures.

In compliance with the EU-US Privacy Shield Principles, SMARTe commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact SMARTe at privacy@smarteinc.com.

SMARTe further has committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to JAMS (Judicial Arbitration & Mediation Services), an independent alternative dispute resolution provider located in the United States and recognized for this purpose by the US Department of Commerce. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information, and to file a complaint.

We may make any Business Information that our users contribute for inclusion in our Directory, that we collect from public web sources or that we license from third parties available to users of the Site, to our strategic partners and to our customers.

Disclosures to Service Providers

SMARTe may from time to time disclose Business Information or other collected information to service providers, solely for providing functions related to our operation of the Site and for no other purpose. For example:

SMARTe uses service providers to process credit card payments on our Site. When you use a credit card to pay for SMARTe services, information such as your name, billing address, phone number, email address and credit card Information will be submitted to service providers for verification and to manage any recurring payments.

SMARTe uses software hosted by a service provider to provide us with information regarding our visitors' activities on our Site. When you visit our Site, that service provider may set cookies on our behalf and may receive information about your browsing activity on our Site.

Disclosures for Legal Reasons

We may disclose collected information, including Business Information, to a third party if we believe in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants or orders by public authorities, including to meet national security or law enforcement requirements, (ii) to address a violation of the law, (iii) to protect the rights, property or safety of SMARTe, its users or the public, or (iv) to allow SMARTe to exercise its legal rights or respond to a legal claim.

Disclosures to a Buyer of the Company

If our company or substantially all of our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to SMARTe may be among the transferred assets. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Other Disclosures

In cases of onward transfers of data, received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield, SMARTe, Inc. is potentially liable. If you register for a SMARTe event with a third-party speaker, your information will generally be shared with the speaker.